OPINION
DAWSON, Judge:
This proceeding is before us for disposition on the basis of separate motions for judgment on the pleadings filed by the parties. The sole issue posed by these motions is whether a judgment of conviction on a charge of willfully attempting to evade or defeat income tax by understating his income, submitting a false statement of his income, and by filing a false and fraudulent income tax return, is conclusive and binding on the...
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